Good remarks you made. I like the way you said it “pool of interpreters”. In other words, we need to be more sensitive to interpreters’ needs. Right on!

Ed

I agree with you what you are trying to say. It boils down to VRS providers – either as certified VRS provider, or riding on other VRS provider – do the requirements. Right now the requirements are minimal. FCC needs to increase requirements to the point where burden of accountability; i.e. consumer driven, ethical, etc. on VRS providers.

eyes open & thumbs up,

Ed

I had been out of town doing business work; was in MD and then NYC. Whirlwind activities. Sorry not to respond sooner.

A few ways to do that:

For existing TRS issue that needs comment; that is, 30 days have not expired yet, go to

http://fjallfoss.fcc.gov/ecfs/Upload/

scroll down to Ten-digit numbering for Internet-based TRS and click on continue and go thru process..this one is fairly easy.

The more complicated one is this one.

http://www.fcc.gov/cgb/ecfs/

And finally the simplest way is send email: fccinfo@fcc.gov Be sure to include docket number otherwise they won’t know. Docket 03-123 and then cite Ten Digit Phone numbering system if that is what you want to comment on. The last one can be for ex-parte as well (ex-parte means deadline to comment has expired or can be for any telecomm issues that are not on the record).

Good luck…

Ed

Here are the links for Healinc Telecomm.

http://www.manta.com/coms2/dnbcompany_6xg09m See the annual sales. Very small.

http://www.scribd.com/doc/2809764/Notice-Common-carrier-services-Interstate-Telecommunications-Relay-Service-Fund-video-relay-service-provider-eligibility-certification

The above certifies Healinc Telecomm as VRS provider.

If FCC certifies based on at least one VRS center, has platform, understands deaf/hoh communities, etc., very likely this company may not be approved.

eyes open & thumbs up,

Ed

You do me proud. Your thoughts are well thought out and to the point.

I sincerely hope VRS providers are reading all these comments and do a thorough internal analysis of their practices. I do know a few FCC folks are reading these comments as well. However, your thoughts as expressed should also be expressed to the FCC by sending them email as it will make an impact as well.

eyes open & thumbs up,

Ed

I am also wondering who GA is trying to hurt here. The small startups or the bigger companies that contract on a regular basis with these smaller companies. I think there are some VRS companies that are notorious for contracting out their VRS services to smaller local entities. These larger companies would also be hurt in a ruling like this.

The whole goal of reducing the minutes usage is to reduce the cost to taxpayers. If FCC had to regulate and certify every little start up company (there could be literally hundreds out there), how much is it going to cost the FCC in manpower to go and inspect each and every one of these smaller entities. There might be some number crunching necessary to find out which is more cost benificial to the taxpayer.

I work in the transportation industry and in our industry the prime contractors are responsible for the work of the subcontractors. If the subcontractor messes up, it’s the prime contractor that has to pay for the mistake. If the FCC can institute effective rules that penalize the VRS companies recieving funds directly from TRS for the noncompliance of the smaller VRS companies they sign contracts with then this issue will probably be minimized without hurting competition.

In conclusion, I believe that if a VRS company chooses to subcontract their work out to smaller a smaller company the prime VRS company should bear the responsibility of compliance. This will allow smaller VRS companies to gain entry into the marketplace through contracts and keep FCC from being overburdened with making sure that every little VRS startup is playing by the rules. If a VRS company is receiving money directly from the fund then all they have to do is meet the same requirements of all other VRS providers that are recieving funds directly from TRS. If the VRS company is recieving money through another VRS provider then the VRS provider who is recieving money directly from the fund is responsible for the compliance of that company. I’ve seen it in practice and I think it will well in the VRS industry.